Promote the National Cyber Security Awareness Month (NCSAM). Get involved and do your part! This is a job for everyone, make an effort to care! The theme for this year is “Our Shared Responsibility”. NCSAM will be observed in October, but make it part of your practice to start today.

For more information on keeping current on cybersecurity, vulnerabilities, data loss prevention, managing risks, and workforce members training, Contact RISC Management and Consulting, LLC at 800.648.4358 or visit www.RISCsecurity.com

Come visit with Virtual Auditor and RISC at the 7th Annual Regional Conference Texas Chapters of HIMSS in Austin! There will be over 400 healthcare IT professionals and optional preconference activities such as legislative visits at the State Capitol and Networking social. The focus will be on promoting the value of investing in Health Information Technology.

Wednesday, February 18, 2015 – Friday, February 20, 2015

Renaissance Austin Hotel

9721 Arboretum Blvd.

Virtual Auditor will be demonstrating an industry-leading Information Security Continuous Monitoring Solution (ISCMS). The ISCMS was specifically developed to help organizations including healthcare, banking, finance, and other heavily regulated industries, to meet their data privacy, information security, and compliance requirements. The ISCMS provides continuous monitoring, alerting, reporting, and event correlation, providing the data your techs want, your security folks wish they had, and your executives need! Visit www.VirtualAuditor.com for more information if you can’t see this amazing technology first hand.

Is Your Organization’s New Years Resolution to Be More Secure? If not, it should be!

However, that is too easy to say, and very hard to accomplish. The current threat environment is expanding far faster than the controls can hope to keep up with. A CISOs / CSOs job has never been harder; a trend that will continue this year and on into the future. If you don’t believe that call up organization’s like SONY, ebay (one of the least talked-about giant data breaches of the year), Target, JPMorgan Chase, Home Depot, Community Health Systems, or the 321 other healthcare organizations reporting breaches affecting over 83 million individuals! In fact, healthcare breaches accounted for a whopping 42.3% of data breaches included in the just-published Identity Theft Resource Center 2014 Data Breach Report(1).

Threat vectors include all of the usual suspects that we have been talking about for years. But the massive proliferation of data, accelerating migration to remote and teleworkers, and huge increase in activity of nation-states, organized crime, and hacktivists all make the CISOs / CSOs job next to impossible. It’s not a matter of whether an incident will happen to a modern connected company, but when.

Data breach incident handling must be a part of your data privacy and information security program. Balancing the need for speed of response, especially prompted by state-level data breach rules, with accuracy and responsible forensic activities is a tough challenge. It becomes tougher when interested parties such as the CEO, who suddenly realized that information security is important, compliance, legal, IT Management, public relations, the cyber security insurance carrier and their forensic experts, and the press all want constant feedback and a complete understanding of what happened, who did it, and how much is this going to cost us? from the word, “Go!”

Hopefully all of these parties were interested when the CISO / CSO asked to run a data breach incident drill last year in order to test the capabilities, response time, and training of all relevant parties to respond to such an incident. From our experience performing risk assessments, they were not, and a drill has never been completed.

Don’t let a real incident be the first time you test your data privacy and information security incident response plan. Remember a successful program is built on statements of policy, supporting procedures, tools, checklists, logs, forms, and training. If a real incident is your first test, chances are you are looking at a poor result, and a poor result is more likely to lead to fines and firings.

Since an incident is a matter of When Not If, testing your incident response plan should not be seen as optional or subject to perpetual procrastination!

Lastly, remember that while Information Technology (I.T.) is the system owner and the primary source of information in the event of an incident or breach, the problem is a business issue, not an I.T. issue! Consider addressing requirements and response in your Business Continuity Plan (BCP). BCP procrastination is a topic for another article!

As a salesperson accountable for the positioning of compliance and security solutions to the Healthcare and Financial verticals, I often find myself in a unique position. This position being, how to digest the following; “We have quite a few other projects on the table”, “We have not budgeted for that”, “We performed an audit/assessment a few years ago”, “We are content with our current status” and related.

Before I get ahead of myself, there is success had in simply gaining a response. Well, that may solely be of value to me and not those interested in my quota attainment so, I digress…. My concern is this, if there is not a plan to have band-aids on hand, how do you plan to address the inevitable blood? According to a recent analysis by a leading IT security firm, of the small portions of IT budgeting set aside for security, corporations often spend as little as 10 percent on incident response, 30 percent on detection and the rest on prevention. That is, if there is any spending. And all of that only if there is concern that results in the establishment of defined needs, requirements and initiatives.

More often than not, action, or should I say reaction, is brought about by the sight of blood.

“Instead of merely blocking threats at the perimeter of a network, a multilayer cyber response that protects every critical component inside the network as well as external connection points is a more effective, proactive approach” (CardVault, 2014, para. 3). This statement reflects the sentiment of a leading cyber security attorney. With external and internal threats both on the rise and inevitable, can your organization afford to be in a reactive position? The thought of “This won’t happen to my network” is about as realistic as a unicorn monitoring USB usage.

My advice is this; Put a fluid security plan in place to address devices, systems, applications, and users. This plan must address the enterprise from the firewall to the desktop. Processes, controls and accountability are critical in this planning. This plan will include human and appliance elements. Ultimately, you must understand that your network is exposed 24x7x365. At any point during this time, there may be blood. Do you have band-aids?

Don’t let the fear of a data breach keep you awake at night: Schedule a vulnerability assessment and learn ways you can protect your systems.

Run a data breach response drill to practice on a scenario so there is less panic when responding to the real thing.

Spend a few minutes learning how to improve privacy protections and security safeguards.

Visit VirtualAuditor.com and www.RISCsecurity.com to learn a great deal more about the various tools we offer to enable healthcare organizations, financial institutions, universities, and business of any size, to effectively monitor, enforce, and audit your confidential information.

Data Loss Prevention, often abbreviated DLP, is no longer an optional solution for organizations that:

Are in possession or use of data that is regulated, confidential, sensitive, or otherwise limited from public access;

Are large enough to have more than a single, structured data repository such as only one server and dumb terminals (hardly the case anymore);

Need to be able to prove to management, auditors, or regulatory bodies that they know where their data is, and how it is being protected.

Business owners should consult with security professionals according to Siciliano (Entrepreneur, 2014), CEO of IDTheftSecurity.com, Inc. Siciliano reported the importance of installing data-loss prevention software and performing a risk assessment, “it’s possible to monitor the entire network’s activities to detect events that could lead to a data breach and detect trespassers before it occurs” (p. 3).

Part of the Guide to Privacy and Security of Health Information explains the HIPAA Security Rule requirement that a covered entity must conduct aRisk Analysis [§ 164.308(a) (1) (ii) (A)] to identify risks and vulnerabilities to electronic protected health information. Performing a “risk analysis is the first step in an organization’s Security Rule compliance efforts” (Office of the National Coordinator for Health Information Technology, 2014, p. 10) in identifying and implementing safeguards that comply with and carry out the standards and implementation specifications in the Security Rule. In addition, organizations must perform an Application and Data Criticality Analysis [§ 164.308(a) (7) (ii) (E)] to, “Assess the relative criticality of specific applications and data…”

The first step in any information security and compliance program is understanding what data your organization has, where it is located, and who is using it; authorized or unauthorized. Complete and accurate knowledge is necessary in order to understand what laws or requirements apply to your organization, and which members of your workforce may require training or monitoring.

Data Classification

Classifying your data into categories such as a Data Classification Matrix makes it easier to apply controls based upon the data type, rather than in a discretionary manner, or simply guessing. Most organizations know that they should protect credit card information differently than public marketing materials. But can they explain the differences in controls applied to ePHI versus Social Security Numbers? What are the requirements for this data? Who enforces them? How much trouble are we in if we have an unauthorized breach of this data?

Every organization should determine the classes that their data types fall into, not the data repositories. For example, classify your data as “Regulated” as opposed to “ePHI” or “Confidential” as opposed to “Payroll Records”. Remember, for data privacy and security regulations and industry requirements, the purpose of the data is irrelevant, it’s the existence of the data that matters.

An example of a data classification matrix that RISC has assisted its clients in successfully deploying is:

Regulated

Confidential

Non-public

Public

Once your data is classified, control mechanisms can be assigned to that classification as a whole, rather than piecemeal.

Now, your DLP solution is ready to find that data, and let you know where it is, at high speed, with pretty good accuracy. A DLP solution, or even a DLP assessment, can perform a year’s worth of human analysis in a week or two of close to pure automation!

An important definition to understand is the term Vulnerability and Technical vulnerability. Vulnerability is defined in NIST (2012) Special Publication (SP) 800-30 as “[a] flaw or weakness in system security procedures, design, implementation, or internal controls that could be exercised (accidentally triggered or intentionally exploited) and result in a security breach or a violation of the system’s security policy.” Technical vulnerabilities may include: holes, flaws or weaknesses in the development of information systems; or incorrectly implemented and/or configured information systems. The NIST (SP) 800-30 guide is a 95 page document published and developed by the National Institute of Standards and Technology (NIST) under the Federal Information Security Management Act (FISMA), Public Law 107-347.

Included in the risks that should be identified by an organization regularly are technical vulnerabilities. These vulnerabilities may include missing patches on computing devices, misconfigurations accidentally performed by staff members or consultants, or insecure network architecture. While the reasons are many, the result is the same, elevated risk to the confidentiality, integrity, and availability of your organization’s sensitive information.

RISC Management & Consulting can assist your organization in performing comprehensive technical vulnerability testing. The Security Engineers at RISC use numerous best in class tools to establish a thorough view of your security posture. The output of these tools is used in a number of ways including:

Comparing security controls and system configuration to organizational policy.

Comparing the state of security to compliance requirements such as HIPAA, PCI-DSS, and ISO 27002.

Comparing the actual network architecture to the organization’s understanding of the network architecture.

Developing a technical vulnerability assessment report that provides a compliance, business, and technical review of the state of information security.

Contact RISC Management and Consulting today to discover how we can help you! www.RISCsecurity.com or 630-270-9336